LEAD – EPA’S LEAD RULES-TOOLBOX TALK

 

LEAD – EPA’S LEAD RULE-TOOLBOX TALK

Lead is harmful when ingested or inhaled. The permissible exposure limit is 50 µg/m3. Lead poisoning can cause developmental and behavioral problems in children and adults. No level of lead is safe, and children are an especially vulnerable population. The Environmental Protection Agency (EPA) has guidelines under the Renovation, Repair, and Painting Program to help reduce exposure to children. Renovation work may put occupants at risk of lead exposure, so the following requirements shall be followed.

EPA RULE

When working in residential houses, apartments, and child-occupied facilities built before 1978, contractors must:

⦁  Distribute the Environmental Protection Agency (EPA)’s lead hazard information pamphlet "Renovate Right" before starting renovation work.

⦁  Document compliance with this requirement; the Environmental Protection Agency (EPA)’s pre-renovation disclosure form may be used.

⦁  Prevent Exposure: use engineering controls + lead-safe work practices

Be Trained:

⦁  Company Certification

⦁  Employees trained in lead-safe work practices to minimize occupant exposure (certified renovators or on-the-job training)

When does the EPA lead rule apply?

In pre-1978 housing and any child-occupied facilities, like schools or daycare centers.

⦁  Remodeling and repair/or maintenance

⦁  Plumbing, carpentry, electrical, and painting preparation.

⦁  Window replacement and partial or full demolition

Exceptions: 

Minor repairs and maintenance that disturb 6 sq. ft. or less of paint per room inside, or 20 sq ft or less on exterior are exempt from the rule.

You should still use engineering controls and work practices to reduce lead exposure.

Prevent Exposure

The permissible exposure limit (PEL) for lead is 50 µg/m3.

Engineering controls and work practices are essential to help reduce the risk of exposure. Use isolation, ventilation, work practices, and good housekeeping and hygiene to reduce exposure levels.

Avoid:

⦁  Open flame burning or torching

⦁  Using a heat gun at temperatures more than 1100F

⦁  Sanding, grinding, planning, etc. with power tools not equipped with a shroud and HEPA vacuum attachment or using wet cutting methods.

If engineering controls are not effective or feasible, you may be required to wear a respirator. You must complete a medical questionnaire, fit test, and training before you wear a required respirator. Contact your safety coordinator with questions.

Lead Safe Work Practices

1. Contain the work area + post warning signs to prevent dust and debris from leaving the work area.

⦁  Contain the area with plastic to isolate

⦁  Cover floors and furniture that can’t be moved

⦁  Seal off doors and heating/cooling vents

2.  Use work practices that limit dust and vapor.

⦁  Use Local Exhaust Ventilation with a HEPA filter when welding/cutting or use hydraulic shears rather than cutting

Use wet methods: 

⦁  Mist the area before sanding or scraping

⦁  Score paint before separating

⦁  Pry/pull apart components rather than breaking them.

⦁  Cut on either side of lead joints, rather than cutting the joint

⦁  Use chemical strippers, power tools (needle guns), or other methods rather than burning to remove lead-based paint from surfaces.

3. Clean up thoroughly

⦁  Clean daily + clean before removing any plastic containment HEPA vacuum + wet wiping and wet mopping with plenty of rinse water.

⦁  Verify all dust and chips are gone before removing the containment area.

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